How you can help

HERE ARE SOME THINGS YOU CAN MENTION TO THE ARMY CORPS OF ENGINEERS IN YOUR COMMENTS:

Direct impacts to bears:

Increased noise levels from construction may deter bears from coming to McNeil River Falls, a prime viewing area.

Dredging off Amakdedori Beach may affect schooling of salmon and/or Dolly Varden before they run up Chenik Creek, McNeil River and Mikfik Creek. McNeil bears are known to eat fish in these as well as other stream systems in the area.

Noise from increased large vessel traffic (boats moving product from the terminal at Amakdedori to the Kenai Peninsula) could affect bear behavior and change or end the use of McNeil River by bears.

It is likely that there will be increased contact between bears that use McNeil River and humans outside the McNeil River program that could result in food conditioning of bears or direct bear mortality by intolerant humans.

The proposed road, resulting traffic and human presence would fragment the habitat and bisect a travel corridor for bears who use resources in the McNeil Refuge and Sanctuary.

Any industrial facility, especially in the heart of bear country, increases the likelihood of bears becoming food conditioned and thus reduce safety for visitors in the refuge and sanctuary.

Direct impacts to the visitor program:

Displacement of bears would reduce the number of bears viewed by people, resulting in a diminished viewing experience and a threat to the visitor program.

Direct mortality of bears from humans would affect the immediate population of bears using McNeil River.

Because the viewing program for visitors at McNeil River is structured around consistency of human behavior many bears using the area have become tolerant of humans. The habituation extends into subsequent generations, as young bears typically follow their mothers’ feeding and home range patterns. Thus, a less immediate though more serious decrease in bears using McNeil River could also be a result of this proposed Pebble Partnership mine project.

Major changes to the Pebble Partnership mine plan – specifically in the transportation corridor to Amakdedori Cove – necessitate a major review of its impact on brown bears and local salmon. The proximity of proposed new roads, facilities, port and dredging so close to the large concentration of brown bears that gather in the McNeil refuge area call for additional attention.

It is CRITICALLY IMPORTANT that as many people as possible comment on impacts of the Pebble Mine proposal during this comment period. It is very important to identify concerns and impacts NOW. If concerns are not addressed during this comment period, it is very unlikely they will be considered later.

Please contact your friends on all social media outlets and forward this site so that they can weigh in. The more people who comment and the wider the range of comments regarding impacts to bears, the better.

More about why it is so important to weigh in:

The Army Corps needs to hear concerns about Pebble’s proposed mine and they need immediate feedback that the egregiously fast-paced process is unacceptable. Unlike past EPA public comment periods, scoping comments to the Army Corps need to focus on the potential impacts the Pebble Mine will have on the lands, waters, people, fish, and wildlife of the region.

Scoping comments will also need to focus on the potential impacts the project will have outside of the mine site itself, including impacts related to the powerplant, pipeline, port, barging, and transportation corridor — items that were not considered or proposed when the EPA held its comment periods. Without citizens raising impacts issues, the Army Corps will draw as small a scope of review as possible, and thereby omit many of the downriver and wider impacts of the Mine.

We will also use this opportunity to contact elected officials in addition to the Army Corps, as they will also be important decision makers related to Pebble going forward.

How to weigh in:

The Army Corps will be hosting the following hearings in (dates and times tentative):

April 9thin King Salmon at school

April 10thin Kokhanok

April 11thin Homer high school 5:30pm (No public testimony)

April 12thin Iliamna

April 16thNondalton

April 17thDLG at 5pm in school gym (No public testimony)

April 18thin Igiugig

April 19thANC at 5pm in Dena’ina center (No public testimony)

The Anchorage, Dillingham, and Homer hearings will have court reporters and the opportunity for individuals to submit public comments. The rest will take public comments at the hearings.

The Army Corps is not accepting emailed comments, so they will have to be submitted to:

Program Manager

Regulatory Division US Army Corps of Engineers

PO Box 6898

Joint Base Elmendorf Richardson, AK 99506-0898

There is also a webform for comments on the PebbleProjectEIS site starting April 1, 2018.

Draft Comment to the Army Corps:

Proposed Pebble Mine Project (POA-2017-271)

To U.S. Army Corps of Engineers:

Protecting Bristol Bay’s fisheries is critical for our economy and culture. The Army Corps of Engineers should protect Bristol Bay, and the businesses and communities these waters support, by considering the following during permitting:

This application is incomplete. The Army Corps should not issue a Draft Environmental Impact Statement without more information from the Pebble Partnership. There is no baseline information for significant parts of Pebble’s proposal, including the proposed transportation corridor, port or use of Lake Iliamna. Any baseline data Pebble has supplied is more than 10 years old and is not a reasonable basis on which to analyze project impacts. The Pebble Partnership should also provide an independently prepared economic feasibility analysis.This is routinely done for other mines like Donlin and without it the Corps could be analyzing and the public could be commenting on a hypothetical mine. To proceed with the NEPA process under these conditions is a waste of government resources and of the people’s time.

The Environmental Protection Agency found that a mine smaller than what Pebble is currently proposing would pose “significant and irreversible harm” to Bristol Bay’s waters and would result in “a complete loss of fish habitat” Pebble’s current plans will permanently destroy 4,000 acres of wetlands and more than 5 miles of anadromous streams, levels that exceed EPA’s proposed restrictions on the mine. The Army Corps must compare Pebble’s plans to the EPA’s analysis before moving forward with permitting.

The Army Corps must look at a range of alternatives beyond Pebble’s mine site and include alternatives for mining copper and gold somewhere other than Bristol Bay.

The Army Corps should use a realistic scope of Pebble mine to assess its impacts. Pebble asks the Corps to limit the review to an unreasonably small 20-year mine that likely is not economic, while it touts to potential investors that the mine can operate for 200 years and have 11 billion tons of ore. The Army Corps must look at the full extent of mining the Pebble deposit, and not ask the public to participate in a process that is founded on a permit application that is missing such basic components.

Please stand with American jobs, Bristol Bay communities, and the millions of Americans that understand the value of these waters. Please reject Pebble’s permit application as incomplete, lacking environmental and economic baseline data, and lacking the information needed for government agencies to assess the massive amount of impacts that Pebble is proposing.

Pebble Scoping Talking Points

The Army Corps is required to analyze the following effects in its EIS and these should be considered when commenting during scoping:

Direct Effects – effects caused by the proposed Pebble mine project itself and all of its related components.

Indirect Effects – effects caused by the proposed Pebble mine project, and that are later in time and farther removed in distance but are still reasonably foreseeable. These include effects such as changes in land use patterns, population density or growth, impacts of transporting ore, impacts of the power plant, and all of the related effects on air and water and the environment from these effects.

Cumulative Effects and reasonably foreseeable future actions– the impacts on the environment resulting from the incremental impacts of the proposed Pebble mine when added to other past, present, and reasonably foreseeable future actions(i.e., other potential projects such as expanding the Pebble mine size or mining other deposits in Bristol Bay).

Direct and indirect effects, as defined above, could be associated with the construction, operation, and closure phases for the major components of the mine site, transportation facilities, port, and pipeline under review in an EIS. Scoping comments should address concerns with each proposed Pebble project component’s direct, indirect, and cumulative effects on:

Climate and Meterology– impacts from air pollutants emitted during mine operations and contribution to greenhouse gas emissions from 230MW powerplant.

Surface water hydrology– impacts to surface water from changes in streamflow, dams and effluent, water balance, flood magnitude and frequency, wetlands, lakes, and ponds filling, surface water extraction from all proposed Pebble project components and during construction, operation, and closure phases.

Groundwater hydrology– impacts to groundwater and aquifers from all proposed Pebble project components and during construction, operation, and closure phases.

Water quality– impacts to surface water, groundwater, and benthic sediment from all proposed Pebble project components and during construction, operation, and closure phases. Includes impacts to marine waters and Lake Iliamna.

Air quality– impacts to air quality (pollutants, visibility, greenhouse gases, etc) from all proposed Pebble project components and during construction, operation, and closure phases. Including impacts from transporting ore and materials to and from the mine site, shipping ore, powerplant emissions, and fugitive dust.

Noise and vibration– impacts on the natural environment and use of the area from noises and vibration during construction and operation, including construction and blasting of the mine facilities and transportation corridor and port, mine operations and rock extracting, powerplant, transportation, etc.

Vegetation– impacts to vegetation (including removal), rare and sensitive plants, and impacts from invasive plants and climate change from all proposed Pebble project components and during construction, operation, and closure phases.

Wetlands– direct filling of more than 4,000 acres of wetlands, destruction of wetlands from dewatering and hydrological changes, pollution to wetlands, impacts on wetlands functions, clearing and removal of wetland vegetation, degrading wetland vegetation and soils, etc. from all proposed Pebble project components and during construction, operation, and closure phases.

Wildlife– impacts to mammals, birds, marine mammals, big game species from habitat destruction and loss, behavioral disturbance, accidental environmental damage, fragmenting of habitats, exposure to contaminated water and dust, exposure to noise, transportation collusions from all proposed Pebble project components and during construction, operation, and closure phases.

Fish and aquatic resources– impacts such as destruction of approximately 20 miles of streams and 4,000 acres of connected wetlands, construction of more than 200 culverts impacting fish passage, long-term contamination from mine effluent and dust deposition in water, accidental spills and tailings dam failures, pipeline failures, impacts to fish, macroinvertebrates, water quality, destruction of aquatic and riparian habitat, increased erosion and sedimentation, etc. [note – this encompasses the EPA’s study]

Endangered and threatened species– Pebble’s proposed port site is designated Critical Habitat for the Cook Inlet Beluga Whale and the Northern Sea Otter, both listed endangered. Lake Iliamna (where Pebble proposes to barge ore across) is home to freshwater seals that have been considered in the past for ESA status. Other ESA listed species that might be located in the project area and in ore shipping routes include Steller’s eider, humpback whale, Steller sea lion, fin whale

Land ownership, management, and use– the proposed mine site and many project components including the port site and a majority of the transportation corridor are proposed on state-owned lands. Mine construction, operation, and closure would limit any access to these lands and transportation corridor to private entities only. A pattern of land use change would occur in the region long-term with additional mining deposits explored for development.

Recreation– impacts to recreation and tourism include increased noise, decreased visibility due to fugitive dust and powerplant and mobile source emissions, scars on the viewshed due to the port, road, and mine site, and perception of contaminated waters, fish, and wildlife

Visual resources– the mine site, transportation corridor, and port will have permanent and significant impacts on the appearance of the landscape as viewed from key observation points, planes, etc. and will in turn impact use and enjoyment of the area by many

Socioeconomics– all project components will have significant impacts on local communities, and infrastructure and services.

Environmental justice– impacts related to environmental justice include food security and subsistence resources, health impacts from pollution and exposure to increased industrial activities and noises, increased risk of injury and exposure to hazardous materials, increased exposure to outsiders and the cascading social and psychological problems that brings (substance abuse, stress, cultural conflicts, etc.)

Cultural resources– impacts to cultural resources (historical and pre-historical sites) and direct destruction of cultural resources from all project components.

Human health– short and long-term impacts from all stages of the project include increased risks of accidents and injuries, exposure to hazardous materials, negative impacts on food, nutrition, and subsistence, increased potential for infectious diseases, risks to clean water and sanitation from population-stressed infrastructure, risks to health and human services from population-stressed infrastructure and services

Existing transportation– impacts to boat traffic (recreation and fishing and shipping) due to port facility shipping and Lake Iliamna barging, increased air traffic during all project phases,

Scoping comments should also focus on unavoidable adverse effects (e.g., the direct and indirect effects as described above that cannot be avoided or mitigated away through permitting stipulations and requirements) to:

Geology and Soils– changes in landforms and reduction in mineral, soil, fossil-bearing bedrock and aggregate resources. Surface and intrusive activities during construction and operations would affect the mechanical and thermal properties of the soil and would modify permafrost distribution.

Surface and Groundwater Hydrology– lowered water table in the vicinity of the mine site; average flow reduction in Upper Talarik Creek, North Fork Koktuli, and South Fork Koktuli; alteration of groundwater flow and elevation; and alteration of streamflow including damming of Bristol Bay headwater tributaries.

Water Quality– surface pit lake water drainages into BB headwaters will exceed water quality standards for some metals and other pollutants and would discharge in perpetuity; atmospheric deposition of mine dust and powerplant emissions could pollute surface waters; catastrophic tailings dam failures or spills during transportation (ferry or truck) could pollute surface waters; pipeline failure under Lake Iliamna or rivers and streams could pollute surface waters.

Vegetation and wetlands– the Pebble mine project proposes to destroy 4,000 acres of wetlands. It is unclear if they will be able to avoid or mitigate these impacts. Additional impacts include changes in vegetation and wetlands because of hydrology changes, potential introduction of non-native and invasive species, removal of vegetation and wetlands.

Wildlife and Threatened and Endangered Species – the Pebble mine project will cause permanent changes in habitat, direct habitat removal, disturbance, and risk of injury or mortality from shipping collisions. The proposal will put a massive shipping port in designated Critical Habitats of the endangered Cook Inlet Beluga Whale and the endangered Northern Sea Otter.

Visual Resources – facilities, infrastructure, equipment, and vegetation clearing would contrast with the natural landscape and impact viewsheds of nearby state and federal parklands. Impacts are permanent and would persist following project closure.

Cultural Resources– changes to cultural landscape and permanent impacts to and destruction of historic and culturally significant sites.

Subsistence– disturbance and displacement from subsistence use areas, potential for increased competition for resources, disturbance to subsistence fishing, and potential contamination of wildlife and waterfowl due to the tailings pond and pit lake.

Hazardous Materials and Spills– petroleum products, liquefied natural gas, mine tailings, and mine slurry chemicals could be spilled as a result of the proposed Pebble mine. Resources that could be adversely affected by spills include vegetation, fish, wildlife, water resources, subsistence harvest and uses, recreation, cultural resources, and the economy.

Climate Change– the proposed Pebble mine project would contribute to global climate change, primarily through the release of greenhouse gases from the burning of fossil fuels during production and shipping. Climate change will in turn impact many aspects of the physical, biological, and social environment, including precipitation patterns, permafrost distribution, vegetation, wildlife, fire regimes, and subsistence.

In addition to the substantive comments laid out above, commenters might also point out concerns about:

Purpose and Need– the need for the Pebble project generally, commenters might point out the alternative ways the world can get copper resources other than mining pristine Bristol Bay headwaters

NEPA Process– express concerns with the procedural aspects of the permitting, such as cooperating agency status, lack of public information, lack of translation, lack of government to government consultation, etc. [note – this will depend a lot on what the process will look like]

Mitigation measures– commenters might point out that Pebble has not put forward a mitigation plan with its permit application, the impacts of the project will be massive and will not be easily mitigated away, and that there are no wetlands, ponds, lakes, and streams that need restoring in Bristol Bay where Pebble can compensate for its destruction.

Bonding– commenters might point out that Pebble will have to put up a massive bond to pay for potential devastating impacts

Operator issues– commenters might point out that PLP is an untrustworthy company, how can we expect them to build a project that will have to be monitored in perpetuity

Lack of data– Pebble has not submitted any baseline data to the Army Corps, Pebble has not compiled any baseline data for its transportation corridor and port site and Lake Iliamna, Pebble’s baseline data is out of date (2004-2008) and cannot be relied on for permitting.

Lack of state permit applications– Pebble has not submitted any permit applications with the State of Alaska and seems to be forcing the state’s hand to issue its permits quickly as the federal permitting process is already underway.